The title of this post isn’t meant to be incendiary or to imply that this generation works less than the previous one or anything of that sort. It’s simply a true statement: College students just don’t work that hard. The Department of Education appears woefully ignorant of this fact in proposing two definitions for a “credit hour.”

The definitions are supposed to help in cases like those of American InterContinental University (AIU). AIU’s accrediting agency caught the institution awarding nine credits for a three-hour class. The accreditor called the practice “egregious,” but renewed AIU’s accreditation anyway. With the new definitions, the Department is hoping to have more leverage over accrediting bodies in future situations like this.

The Department has sought a way to protect financial aid expenditures from abuse by explicitly defining what constitutes a “credit hour.” It has created two definitions, and the first one is all about time, defining a credit hour as, “one hour of classroom or direct faculty instruction and a minimum of two hours of out of class student work each week for approximately fifteen weeks for one semester or trimester hour of credit,” or equivalent amounts of time through other schedules. This is called the “Carnegie unit,” and it’s a commonly repeated maxim letting students know about how much they should work for each class.

The problem is that very few students actually put in this amount of effort. Every year, the National Survey of Student Engagement (NSSE, prounced “nessie”) asks college students about their perceptions of their college or university (institutional participation is voluntary, but over 1,300 schools have chosen to participate). One of these questions asks students how many hours per week they spend preparing for class by studying, reading, writing, doing homework, rehearsing, or any other academic activity outside of the classroom.

To meet the Department’s rule for what counts as a credit hour, full-time students, those taking 12 or more credit hours per semester, would have to spend at least 24 hours per week on these activities. But they’re not. In the 2009 version of NSSE, only 10 percent of full-time college freshmen said they work that hard, while the number for seniors was only marginally higher. In other words, very few existing credit hours would meet the Department’s first definition.

If the first definition doesn’t apply, the second definition is overly vague. It requires institutions to establish, “reasonable equivalencies for the amount of work required in [the previous definition] for the credit hours awarded, including as represented in intended learning outcomes and verified by evidence of student achievement.” If the Department has some grand plan to regulate what constitutes a “learning outcome” or “evidence of student achievement,” that’s news to me. If they don’t (and let’s be honest, they don’t), we’re basically left with the same wild frontier we’ve always had, relying mostly on the lax oversight of the accrediting agencies.

The Department’s efforts on gainful employment and student loan default rates are more promising routes to get serious about holding institutions accountable. The feds could also be stronger on graduation and retention rates. Defining a credit hour, especially with two definitions that are so amorphous, and then attempting to hold accrediting agencies accountable for holding institutions accountable, is a backdoor route that’s unlikely to produce results.